R. v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 09/26/17 ORDERING that the date for defendant to respond the plaintiff's 17 Motion for Summary Judgment is EXTENDED to 10/27/17. (Benson, A.)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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VERA RADOVA on behalf of ROMAN

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RADOVA

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Plaintiff,
vs.
NANCY A. BERRYHILL
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:17-cv-00187-CKD
JOINT STIPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME FOR DEFENDANT TO
RESPOND TO PLAINTIFF’S MOTION
FOR SUMMARY JDUGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from

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September 27, 2017 to October 27, 2017. This is Defendant’s first request for extension. Good

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cause exists to grant Defendant’s request for extension. Additional time is required as counsel

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for Defendant has been suffering from ongoing debilitating chronic migraines, which impairs her

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vision. Counsel for Defendant has over 50+ active pending matters, of which require 2+

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dispositive motions until mid-October. As a result of Counsel’s chronic migraines, she had to

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take intermittent medical leave and became behind on her heavy caseload. As a result,
JS and PO for Extension of Time; 2:17-cv-00187-CKD

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Defendant needs additional time to properly respond to Plaintiff’s Motion for Summary

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Judgment. Counsel for Defendant apologizes for the belated nature of this request, but did not

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anticipate seeking an extension due to her ongoing medical condition. Defendant makes this

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request in good faith with no intention to unduly delay the proceedings. The parties further

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stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: September 22, 2017

s/ *Jesse Kaplan
(*as authorized by email on September 22, 2017)
JESSE KAPLAN
Attorney for Plaintiff

Dated: September 22, 2017

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER

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APPROVED AND SO ORDERED:
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Dated: September 26, 2017

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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JS and PO for Extension of Time; 2:17-cv-00187-CKD

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